RIICEIVEL)
DOCKET SECTION
SE?26 4 39 PH ‘97
BEFORE THE
POSTAL RATE COMMISSION &$‘$:;,“;:‘;~~~;
WASHINGTON,
D.C. 20268-0001
POSTAL RATE AND FEE CHANGES, 1997
Docket No. R97-1
i
RESPONSE OF UNITED STATES POSTAL SERVICE
WITNESS SHARKEY TO INTERROGATORIES
OF
THE ASSOCIATION
OF PRIORTY MAIL USERS, INC.
(APMUIUSPS-T33-l-8,
10-12)
The United States Postal Service hereby provides responses
Sharkey to the following
APMUIUSPS-T3,3-l-8,
APMUIUSPS-T33-9
Each interrogatory
interrogatories
of the Association
10-12, filed on September
and 13 were redirected
of witness
of Priorty Mail Users, Inc.:
12, 1997.
Interrogatories
to witness Modert.
is stated verbatim and is followed by the response
Respectfully
submitted,
UNITED STATES
POSTAL SERVICE
By its attorneys:
Daniel J. Foucheaux, Jr.
Chief Counsel, Ratemaking
/hqz/-Richard T. Coooer
475 L’Enfant Plaza West, S.W.
Washington, D.C. 20260-I 137
(202) 268-2993; Fax -5402
September 26, 1997
Response of U.S. Postal Service Witness Sharkey to
Interrogatories of the Association of Priority Mail Users
APMUKJSPS-T33-1,. Please refer to the service commitments submitted in compliance with
Commission Rule 54r:n).
Please explain the difference between service standards and service commitments.
a.
Are the service commiunents for Priority Mail identical to the service standards for
b.
Priority Mail’? If not, please explain the difference.
Are the service commitments for First-Class Mail identical to the service standards for
c.
First-Class Mail? If not, please explain the difference.
Are the service standards for Priority Maii identical to the service standards for Firstd.
Class Mail? If not, please explain the difference.
Are the service commitments for Priority Mail identical to the service commitments for
e.
First-Class Mail? If not, please explain the difference.
What
are (i) the Priority Mail service commitments and (ii) the Priority Mail service
f.
standards from New York City to Los Angeles?
To what extent does the area receiving a 2-day Priority Mail service commitment differ
.!s.
from the area receiving a 2.day service commitment for First-Class Mail?
Response:
a. It is my understanding that these two terms in common usage are interchangeable. One
distinction that may be made by some is that service standards relate to the targets or goals
that have been established by the USPS. Service commitments are either overnight, two-day
or three-day for First-Class Mail depending on the distance that the mail piece will travel
from entry point. to the delivery point. Throughout the following responses. however, the
terms “service standards” and “service commitments” will be used interchangeably
b. Yes. See response to a.
Response of U.S. Postal Service Witness Sharkey to
Interrogatories of the Association of Priority Mail Users
c. Yes. See response to (a.).
d. No. See Witness O’Hara response to APMUKJSPS-T3-2.
e. No. See Witness O’Hara response to APMUIUSPS-T3-2.
f.
(i) The Priority Mail service commitment from New York City to Los, Angeles is 2 days.
(ii) See answer to T33-1, d.
g. There are 155.515 two-day First-Class pairs and 749,886 Priority Mail two-day pairs
excluding APOiFPO and unique IRS origins.
Response of U.S. Postal Service Witness Sharkey to
Interrogatories of the Association of Priority Mail Users
APMUIUSPS-T33-2. In your response to UPS/USPS-T33-1. you refer to the development and
activation of a two-day Priority Mail Network in selected northeastern states.
a.
How will this network affect Priority Mail service commitmentsist.andards in the Test
Year’?
Does the Postal Service expect the entire continental United States eventually to be
b.
served by such networks’?
Does the Postal Service expect the entire continental United States eventually to be
C.
covered by a single such network. with a national two-day service
commitment/standard and a target of 96.5 percent two-day delivery?
Response:
a. See Witness O’Hara Response to APMUIUSPS-T30-4
b. It is not known at this time whether the PMPC network will cover the entire continental
United States.
Response of U.S. Postal Service Witness Sharkey to
Interrogatories of the Association of Priority Mail Users
APMUKJSPS-T33-3.
a.
b.
Will the Postal Service or the network operator contract wirh an independent third party
to provide external performance measurement system data (i.e., end-to-end or depositto-delivery performance) to the Postal Service to demonstrate its success in providing
96.5 percenr on-time two-day service for all destinations within the contract’s service
area? If not. how does rhe Postal Service plan to determine whether the contractor has
met the 96.5 percent target for two-day delivery’?
If external performance data will be collected, will the Postal Service publish or
routinely makl: such data available to rhe public?
a. The two-day goal of 96.5 % is from USPS tender of Priority Mail to thlz Contractor to the
Contractor delivery back to the USPS. Conformance to quality indicators will be monitored
through a USPS-approved sampling system
b. Not applicable.
Response of U.S. Postal Service Witness Sharkey to
Interrogatories of the Association of Priority Mail Users
APMUIUSPS-T33-4. Wirness Treworgy (USPS-T22) in his testimony, on page 3, footnote 2,
stated that the current “external Priority Mail service performance measurement system
provides information on only 301 3-digit ZIP Codes.”
a.
‘b.
c.
d.
e.
f.
g.
Please explain when this system began and what it measures. Does it measure actual
time to deliver to the addressee’?
For each quarter of PFY 96 and PFY 97, please provide all available service
performance data with respect to this external service performance measurement
system.
Please identify the extent to which service standards/commitments were met or
(0
exceeded.
(ii)
Please identify the service performance of Priority Mail with overnight service
standards/commitments.
Please identify the service performance of Priority Mail with two-day service
(iii)
standards/commitments.
(iv)
Please identify the service performance of Priority Mail with three-day service
standards/commitments.
If the areas covered by this system have changed during the time period in question,
please publish the data in columns so that the performance for identical areas are
provided for each quarter.
What level of statistical reliability does the Postal Service accord to these data? Please
compare and contrast their reliability to the results of the external First Class (EXFC)
service performance measurement system.
How does this performance measurement system track when a mailpiece was received
and when it was delivered?
When does the Postal Service expect to provide such information for all Priority Mail’?
How many 3-digit zip codes are included in the EXFC service performance
measurement system?
Response:
a. An external mea,surement of Priority Mail service performance was implemented on
September 13, 1997 at the beginning of Postal Quarter I, FY98. It measures time to
deliver to the addressee. Witness Treworgy was referring to a developmental pilot
Response of U.S. Postal Service Witness Sharkey to
Interrogatories of the Association of Priority Mail Users
which was the forerunner of the actual system implemented,
The description of the
development pilot as a “system” was in error.
b.
(i) In FY 1996 and FY 1997. ODIS was used to indicate operational performance, but not
indicate service. Therefore, there exist no data which measure delivery performance to
standard for Priority Mail.
(ii) See answer for T33-4, b(i).
(iii) See answer for T33-4, b(i).
(iv) See answer for T33-4, b(i).
c.
See answer for T33-4. b(i).
d
The new Priority Mail measurement system is reliable at an average (of
95 % + or
3 or 4 points at the Performance Cluster level. The EXFC system is reliable
at an average of 95 % + or - 4 points at the city level.
e.
Both EXFC and the new priority Mail measurement system operate in the same way.
An independent contractor hires individuals who “seed “ (system parlance, meaning to
drop mail ) in collection boxes or business chutes in buildings. The pieces are
delivered to independent reporters unknown to the Postal Service. Results are
telephoned to the contractor who calculates the results and provides them to the
Postal Service.
f.
No public disclosure of Priority Mail results is expected at this time.
g.
302.
Response of U.S. Postal Service Witness Sharkey to
Interrogatories of the Association of Priority Mail Users
APMUNSPS-T33-5.
a.
b.
For each quarter of PFY 96 and PFY 97. please provide all pertinent information
(based on ODIS time-in-transit data or any other service performance measurement
system used by the Postal Service (excepting that requested in APMUIUSPS-T33-4)
indicative of delivery service provided to Priority Mail. Please provide all available
details concerning the number of pieces receiving delivery in two days, three days, four
days, etc.
What level of statistical reliability does the Postal Service accord to the ODIS data and
other data that either measure or indicate the service performance of Priority Mail?
Response:
a. There is no reliable data to measure the actual delivery service provided to Priority Mail.
b. Not applicable
Response of U.S. Postal Service Witness Sharkey to
Interrogatories of the Association of Priority Mail Users
APMUIUSPS-T33-6.
a.
b.
For each quarter in PFY 96 and PFY 97, please provide copies of Service Performance
Quarterly Reports for First-Class Mail based on the EXFC service performance
measurement system.
Please provide data on First-Class Mail service performance which corresponds to the
data provided regarding Priority Mail service performance in response to DMAIUSPST4-31(b).
Response:
a. See Witness Moden response to DMAIUSPS-T4-3lb,
and below:
EXFC National Scores
PQl-FY96
Overnight
Two-day
Three-day
07.76
79.49
82 24
PQZ-FY96
87.31
75.54
70 93
PQ4-FY97 results have not been released
b. There is no existing First-Class Mail service performance results that corresponds to
Priority Mail results for two reasons. No reliable Priority Mail results exist since the
system has just recently been implemented and EXFC measures at the: city level while
Priority Mail is measured at the Performance Cluster level.
Response of U.S. Postal Service Witness Sharkey to
Interrogatories of the Association of Priority Mail Users
APMU/USPS-T33-7. Does the Postal Service contmue to measure time-in-transit for FirstClass Mail based on ODIS data? If so, please provide rhe ODIS raw data and percentages for
the same time period covered by the EXFC data provided in response to APMUIUSPS-T33-6.
Response:
In ODJS. estimates of time-in-transit are still generated. The estimates are generated and
published quarterly in the Postal Service’s ODIS Quarterly Stacisrics Reports, which are on file
at the Postal Rate Commission, as well as, the Postal Service’s Library at L’Enfant Plaza
Response of U.S. Postal Service Witness Sharkey to
interrogatories of the Association of Priority Mail Users
APMUIUSPS-T33-8.
For each quarter in PFY 96 and PFY 97. please provide copies of all analyses,
statistical calculations, estimates, measures, etc. that the Postal Service prepared in the normal
course of business that show the average number of days late, the distribution of “days late”
(vis-a-vis the service standard), standard deviation in delivery times, consistency of delivery,
analysis of the best and worst cities, etc., for First-Class Mail.
See response to APMUIUSPS-T33-6
(a).
Response of U.S. Postal Service Witness Sharkey to
Interrogatories of the Association of Priority Mail Users
APMURJSPS-T33-10. Please describe each statistical measure used by the Postal Service to
estimate the consistency with which any class of mail is delivered, identifying the source of the
data used to quantify the estimate. listing the class of mail to which the measure(s) has (have)
been apphed, and providing all actual estimates for Base Year 1996.
See response to APMUIUSPS-T33-6
and 7
--
Response of U.S. Postal Service Witness Sharkey to
Interrogatories of the Association of Priority Mail Users
APMUIUSPS-T33-11. Does the Postal Service have any data (e.g.. ODE data. external
measurement performance data) that measure the service performance of First-Class Mail,
Priority Mail and/or Express Mail on a comparable basis? If so, please describe the extent
and types of performance data that are common to all. and provide any service performance
data common to all three products not otherwise provided in response to APMU’s other
interrogatories herein.
Response:
There is no comparable external performance measurement
-
Response of U.S. Postal Service Witness Sharkey to
Interrogatories of the Association of Priority Mail Users
APMUNSPS-T33-12.
Does the Postal Service have any statistical basis demonstrating that
during Base Year 1996 Priority Mail, on average, received faster delivery, or better service in
any other way (e.g., more consistent delivery) than First-Class Mail? If so, please provide
copies of all data and/or studies that support such a position.
Response:
See answer for T33-4, b(i)
DECLARATION
I, Thomas M. Sharkey, declare under penalty of perjury that the foregoing
answers are true and correct, to the best of my knowledge, information,
and belief
CERTIFICATE
OF SERVICE
I hereby certify that I have this day served the foregoing
participants
of record in this proceeding
in accordance
upon all
with section 12 of the Rules
of Practice.
Richard T. Cooper
475 L’Enfant Plaza West, S.W.
Washington, D.C. 20260-I 137
September 26, 1997
document